Annual Inspection

Silvaire · Jan 29, 2015

If all you had were the FAR's how would you define it?

Tom-D · Jan 29, 2015

Appendix D to Part 43
Scope and Detail of Items (as Applicable to the Particular Aircraft) To Be Included in Annual and 100-Hour Inspections

&

91.409 Inspections.

Silvaire · Jan 29, 2015

Correct Tom - so if there were a logbook entry signed by a licensed A&P/IA stating that the aircraft had been inspected in accordance with an "annual" inspection would there be any justifiable reason for anyone reading that entry to consider it as having any alternative meaning other than (at the very least) the scope and detail of Part 43 Appendix D?

flyingmoose · Jan 30, 2015

As a minimum? No I wouldn't think so.

poadeleted20 · Jan 30, 2015

...and only the minimum listed in the regs.

flyingron · Jan 30, 2015

The terse statement that the aircraft had an "annual inspection" and the appropriate return to service entry (note that an annual doesn't necessarily result in an airworthy airplane, and the person who returns it to airworthy service isn't necessarily the person who conducted the inspection) is all that is required.

There are few reasons for a more detailed log entry on the annual:

1. There is often maintenance beyond the actual inspection performed. This also needs to be explicitly logged.
2. There is sometimes useful but not obligatory information (things like compression readings) that is stuck there for the want of a better place.
3. General CYA on the part of the mechanic to demonstrate he did do the full scope.

poadeleted20 · Jan 30, 2015

flyingron said:
The terse statement that the aircraft had an "annual inspection" and the appropriate return to service entry (note that an annual doesn't necessarily result in an airworthy airplane, and the person who returns it to airworthy service isn't necessarily the person who conducted the inspection) is all that is required.

There are few reasons for a more detailed log entry on the annual:

1. There is often maintenance beyond the actual inspection performed. This also needs to be explicitly logged.
2. There is sometimes useful but not obligatory information (things like compression readings) that is stuck there for the want of a better place.
3. General CYA on the part of the mechanic to demonstrate he did do the full scope.

All good reasons to see more, but if all the mechanic did was exactly what is required by the regs, I don't see the regulatory requirement to say more than that an annual inspection was completed. If I were looking at that plane to fly or buy, I might want to see more, but I don't see any violation of the regulations if that's all there is and that is all that was actually done.

Checkout_my_Six · Jan 30, 2015

Tom-D said:
Appendix D to Part 43
Scope and Detail of Items (as Applicable to the Particular Aircraft) To Be Included in Annual and 100-Hour Inspections

&

91.409 Inspections.

so....you are logging each inspection item? :yikes:

Here's an example from the IA study guide FAA-G-8082-19....

bnt83 · Jan 30, 2015

I log the maintenance I feel is pertinent then sign if off at the end similar to the IA guide. There is no reason to nuts tho my log entries tend to be the longest I've seen, especially when installing repaired parts with 8130 releases and/or preforming alterations.

FastEddieB · Jan 30, 2015

Bear in mind that Light Sports have a few significant differences in the language used in the signoff.

Tom-D · Jan 30, 2015

Silvaire said:
Correct Tom - so if there were a logbook entry signed by a licensed A&P/IA stating that the aircraft had been inspected in accordance with an "annual" inspection would there be any justifiable reason for anyone reading that entry to consider it as having any alternative meaning other than (at the very least) the scope and detail of Part 43 Appendix D?

The sign off should read the same verbiage of FAR 43. There would be no doubt the annual was completed.

But.

When you sign the annual off as completed In accordance with Are you saying that you did every thing in the reference?

Using the Cessna 100 service manual, there is an inspection section, is the sign off insinuating that whole section was completed?

Tom-D · Jan 30, 2015

Ron Levy said:
All good reasons to see more, but if all the mechanic did was exactly what is required by the regs, I don't see the regulatory requirement to say more than that an annual inspection was completed. If I were looking at that plane to fly or buy, I might want to see more, but I don't see any violation of the regulations if that's all there is and that is all that was actually done.

I see several aircraft each year that are totally maintained by their owner, all maintenance is under their name, only the annual is under mine.

Tom-D · Jan 30, 2015

Checkout_my_Six said:
so....you are logging each inspection item?

Why would you assume that?

poadeleted20 · Jan 30, 2015

Tom-D said:
I see several aircraft each year that are totally maintained by their owner, all maintenance is under their name, only the annual is under mine.

Well, if it's "maintenance", I hope they have an A&P, but they can certainly do "preventive maintenance" (which is not "maintenance") on their own.

Maintenance means inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance.

But that's not the issue here since the question was just about log entries for the annual inspection (or so I thought).

Tom-D · Jan 30, 2015

flyingron said:
The terse statement that the aircraft had an "annual inspection" and the appropriate return to service entry (note that an annual doesn't necessarily result in an airworthy airplane, and the person who returns it to airworthy service isn't necessarily the person who conducted the inspection) is all that is required.

There are few reasons for a more detailed log entry on the annual:

1. There is often maintenance beyond the actual inspection performed. This also needs to be explicitly logged.
2. There is sometimes useful but not obligatory information (things like compression readings) that is stuck there for the want of a better place.
3. General CYA on the part of the mechanic to demonstrate he did do the full scope.

When the aircraft is signed off as un airworthy, the verbiage is different.

There is no regulation forbidding the maintenance preformed during the inspection from being included in the same entry for the annual.

There is no requirement to place the compression check numbers in the maintenance records.

poadeleted20 · Jan 30, 2015

Tom-D said:
There is no regulation forbidding the maintenance preformed during the inspection from being included in the same entry for the annual.

Agreed, and that's what I see about 95% of the time, but if anything not included in the regulatory description of an annual inspection is done, there are regulations requiring that it be entered in the maintenance records along with the inspection, as either one omnibus entry or a separate entry detailing the other maintenance. And I have seen split entries where all the maintenance work is one entry signed by someone with only an A&P, and the inspection itself is another entry signed by different person with an IA.

flyingron · Jan 30, 2015

Tom-D said:
When the aircraft is signed off as un airworthy, the verbiage is different.

Agreed. Never said otherwise.

There is no regulation forbidding the maintenance preformed during the inspection from being included in the same entry for the annual.

Agreed. That was my point. The whole point of my post was why there was more text than just "performed annual inspection" in the annual log entry.

There is no requirement to place the compression check numbers in the maintenance records.

I believe I said that. Do you not understand the words "useful but not obligatory?"

Do you feel obliged to denigrate anybody other than yourself who comments on aircraft maintenance?

Witmo · Jan 30, 2015

I don't believe an IA should write a logbook entry declaring an aircraft unairworthy. At most he should complete the annual and provide a list of discrepancies to the owner stating so in the logbook entry and obviously not stating anything about it being in an airworthy condition. It's the owner's responsibility to have the discrepancies cleared and the authorized person clearing the discrepancies signs the return to service for each discrepancy.

Tom-D · Jan 30, 2015

flyingron;1685004 Do you feel obliged to denigrate anybody other than yourself who comments on aircraft maintenance?[/QUOTE said:
No, but I do expound on comments by others.

Tom-D · Jan 30, 2015

Ron Levy said:
Well, if it's "maintenance", I hope they have an A&P, but they can certainly do "preventive maintenance" (which is not "maintenance") on their own.
But that's not the issue here since the question was just about log entries for the annual inspection (or so I thought).

A&P's do own aircraft.

Tom-D · Jan 30, 2015

Witmo said:
I don't believe an IA should write a logbook entry declaring an aircraft unairworthy. At most he should complete the annual and provide a list of discrepancies to the owner stating so in the logbook entry and obviously not stating anything about it being in an airworthy condition. It's the owner's responsibility to have the discrepancies cleared and the authorized person clearing the discrepancies signs the return to service for each discrepancy.

I do believe that placing safety of flight discrepancies in the maintenance records is at the prerogative of the inspector, there is no rule saying you can't.

If there is a possibility of some unsuspecting Ferry pilot getting killed, I'm not beyond doing it.

Tom-D · Jan 30, 2015

Most IAs that I know will work with the owners on unairworthy discrepancies, and allow the discrepancies to be repaired prior to making the annual sign off. ( as airworthy)

Silvaire · Jan 30, 2015

My point is that the term "annual inspection" is defined in the FAR's by Part 43 Appendix D, the header of which reads:

Appendix D to Part 43—Scope and Detail of Items (as Applicable to the Particular Aircraft) To Be Included in Annual and 100-Hour Inspections

and that at no other place in the regulations is an alternate definition given.

The other day a kid was going to take his Private Pilot check ride in a 150 that I did an annual inspection on last year and which was signed off as I normally sign them off - in accordance with an annual inspection.

The examiner refused to allow the aircraft to be flown based on nothing other than he didn't like that wording. He also apparently has led the owners to believe that the aircraft is unairworthy and grounded.

RotorAndWing · Jan 30, 2015

Silvaire said:
My point is that the term "annual inspection" is defined in the FAR's by Part 43 Appendix D, the header of which reads:

and that at no other place in the regulations is an alternate definition given.

The other day a kid was going to take his Private Pilot check ride in a 150 that I did an annual inspection on last year and which was signed off as I normally sign them off - in accordance with an annual inspection.

The examiner refused to allow the aircraft to be flown based on nothing other than he didn't like that wording. He also apparently has led the owners to believe that the aircraft is unairworthy and grounded.

Witmo · Jan 30, 2015

Silvaire said:
My point is that the term "annual inspection" is defined in the FAR's by Part 43 Appendix D, the header of which reads:

and that at no other place in the regulations is an alternate definition given.

The other day a kid was going to take his Private Pilot check ride in a 150 that I did an annual inspection on last year and which was signed off as I normally sign them off - in accordance with an annual inspection.

The examiner refused to allow the aircraft to be flown based on nothing other than he didn't like that wording. He also apparently has led the owners to believe that the aircraft is unairworthy and grounded.

What came of this? Sounds like the examiner needed a talkin to.

Checkout_my_Six · Jan 30, 2015

Witmo said:
What came of this? Sounds like the examiner needed a talkin to.

Ah...yup.

Tom-D · Jan 30, 2015

Witmo said:
What came of this? Sounds like the examiner needed a talkin to.

I know of two DPEs that refused a ride in two different aircraft because the aircraft had no annual sign off in the engine and prop logs.

I gave them my PMI's number and asked them to get guidance. They did. now we have no problems.

Silvaire · Jan 30, 2015

I haven't met this guy nor talked to him and it's probably best I don't because he's most definitely not going to like what I have to say to him. The owner is trying to placate him and smooth things over so he brought the logbooks to me and in an attempt to make everyone happy I made an entry stating the following:

This entry is to clarify that the term "annual inspection" as written in the log entry of Feb 1 2014 and in all other instances herein is to be understood as the equivalent of the scope and detail of FAR Part 43 Appendix D as it is defined therein and that no other definition either fabricated or imagined is applicable.

That apparently however was not satisfactory as the new beef now is that there is no propeller logbook. How this little 150 managed to clock over 8,000 hours in the sky over the past 47 years with no propeller logbook is a real mystery to me :rolleyes2:

If I were that kid I think the action I'd be taking would be to stop payment on the check and find a new examiner. Imagine the poor kids views on aviation after having endured an initiation such as this. :mad2:

Tom-D · Jan 30, 2015

Silvaire said:
I haven't met this guy nor talked to him and it's probably best I don't because he's most definitely not going to like what I have to say to him. The owner is trying to placate him and smooth things over so he brought the logbooks to me and in an attempt to make everyone happy I made an entry stating the following:

That apparently however was not satisfactory as the new beef now is that there is no propeller logbook. How this little 150 managed to clock over 8,000 hours in the sky over the past 47 years with no propeller logbook is a real mystery to me

If I were that kid I think the action I'd be taking would be to stop payment on the check and find a new examiner. Imagine the poor kids views on aviation after having endured an initiation such as this.

Are you sure there isn't a section in the maintenance records that the prop notations are made?

The new adaption by the FAA says there will be a record for each. (engine,airframe, and prop)

I would get the FSDO involved. this guy needs some guidance.

poadeleted20 · Jan 30, 2015

Tom-D said:
The new adaption by the FAA says there will be a record for each. (engine,airframe, and prop)

That's guidance/recommendation from the Engine and Propeller Directorate, not regulation.

I would get the FSDO involved. this guy needs some guidance.

Agreed.

Silvaire · Jan 30, 2015

Tom-D said:
Are you sure there isn't a section in the maintenance records that the prop notations are made?...

Well of course there is because if "annual inspection" is considered to mean the equivalent of the scope and detail of Part 43 appendix D one only needs to read section (h) of appendix D which states:

Each person performing an annual or 100-hour inspection shall inspect (where applicable) the following components of the propeller group:...

Tom-D said:
...The new adaption by the FAA says there will be a record for each. (engine,airframe, and prop)...

What "new adaptation" would that be? Honestly, nobody ever told me about it and if such a thing exists what becomes of all the records kept prior to the new adaptation? Is there a grandfather date prior to which it's okay not to have a propeller log?

My recent experience shows me that there are people out there who are WAY over thinking this. Appendix D is already written and if a licensed A&P mechanic states that an inspection has been accomplished in accordance with it then that is what that means. There is no reason for the mechanic to repeat or re-write appendix D and certainly no reason for anyone to question the validity of that statement.

Tom-D · Jan 30, 2015

Silvaire said:
Well of course there is because if "annual inspection" is considered to mean the equivalent of the scope and detail of Part 43 appendix D one only needs to read section (h) of appendix D which states:

What "new adaptation" would that be? Honestly, nobody ever told me about it and if such a thing exists what becomes of all the records kept prior to the new adaptation? Is there a grandfather date prior to which it's okay not to have a propeller log?

My recent experience shows me that there are people out there who are WAY over thinking this. Appendix D is already written and if a licensed A&P mechanic states that an inspection has been accomplished in accordance with it then that is what that means. There is no reason for the mechanic to repeat or re-write appendix D and certainly no reason for anyone to question the validity of that statement.

I understand -D, I was addressing the lack of a prop log. some times they are hidden in the engine or airframe log.

interpretation would have been a better wording

91.417
(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include—

poadeleted20 · Jan 30, 2015

Here's the Engine & Propeller Directorate's full response to my query on this point:

The answer to your question about separate propeller logbooks can be found in AC 43-9C Maintenance Records 6/8/98.

That AC states: "Section 91.417(a)(l). Requires a record of maintenance, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. This does not require separate or individual records for each of these items. It does require the information specified in sections 91.417(a)( 1) through 91.417(a)(2)(vi) to be kept for each item as appropriate. As a practical matter, many owners and operators find it advantageous to keep separate or individual records since it facilitates transfer of the record with the item when ownership changes. Section 91.417(a)( 1) has no counterpart in section 43.9 or section 43.11."

Although a separate propeller logbook is not required we encourage owners to maintain a separate logbook for the propeller. A propeller logbook is an appropriate document for recording total time in service and time since overhaul as well as details of maintenance, inspections and damage. In some cases, lack of records may require premature maintenance activity, overhaul, or possible propeller retirement since most ADs presume if the time in service and time since overhaul is not known, the propeller requires compliance with the most restrictive level called out in the AD.

As I said, a separate prop log is recommended by the FAA, but not required by regulation.

Tom-D · Jan 30, 2015

Ron Levy said:
Here's the Engine & Propeller Directorate's full response to my query on this point:

As I said, a separate prop log is recommended by the FAA, but not required by regulation.

Which takes precedence ? a AC or a Regulation?

FAR 91 as you quoted above requires a maintenance record.
Quote
Requires a record of maintenance, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. This does not require separate or individual records for each of these items.

poadeleted20 · Jan 30, 2015

Tom-D said:
Which takes precedence ? a AC or a Regulation?

Neither. A regulation sets out requirements. AC's set out FAA-acceptable ways to comply with the regulations, but they may not be the only ways to comply with the regulations.

Tom-D · Jan 30, 2015

Ron Levy said:
Neither. A regulation sets out requirements. AC's set out FAA-acceptable ways to comply with the regulations, but they may not be the only ways to comply with the regulations.

we all knew that.

Do you know of anyone who was violated for a AC?

"Section 91.417(a)(l). Requires a record of maintenance, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft.

from your own reference.

weirdjim · Jan 30, 2015

Ron Levy said:
Well, if it's "maintenance", I hope they have an A&P, but they can certainly do "preventive maintenance" (which is not "maintenance") on their own.

The hell they can't. If I sign after it, I've approved their maintenance with my A&P and then the airworthiness with my IA. WHy the hell don't you just leave this thread and go your way?

....,

poadeleted20 · Jan 31, 2015

Tom-D said:
we all knew that.

Then why did you ask?

flyingron · Jan 31, 2015

But there's no point in arguing the "which one takes priority" when the AC doesn't even say anything contradictory. It reiterates that the regulation doesn't require it but it might be a good idea to have the separate. "Encourage" is a far cry from "Shall."

Tom-D · Jan 31, 2015

Ron Levy said:
Then why did you ask?

Because you didn't seem to know. Your statement inferred that the AC was the Regulation, It isn't, Far 91.417 is and it requires a maintenance record be kept for each component mentioned.

I don't even know why you brought the AC into the conversation, when the FAR is perfectly clear.

Annual Inspection

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